IREG Update October 2019

IREG met on the 9th October 2019 and discussed the following MRA Issue Forms (MIFs) and Electricity Central Online Enquiry Service (ECOES) changes.

MIF219 – Full review of the Working Practice Product Set (WPPS)

IREG received an update of the progress of the review. IREG noted the further analysis carried out on the remaining Working Practices and agreed to continue the review. It noted that there were still Working Practices (WPs) that could be removed from the WPPS due to redundancy. As such it agreed that the drafted Change Proposal (CP) to remove WP141 could be progressed to MDB.

MIF288 – Industry Contacts Database

IREG were advised that Gemserv had completed the internal User Acceptance Testing (UAT) alongside the MRASCo Website Technical Service Provider (TSP). IREG noted that Gemserv had received several data cleanse contact spreadsheets from parties, however, it had been identified that a vast proportion of the data was incomplete. The Chair advised that the spreadsheets would be reissued out for parties to complete and return.

MIF301 – Post Implementation review of the DTC CP 3554

The Chair presented the breakdown of the D0304 and D0312 Data Flow Validation Rules to the group. IREG noted the information presented and agreed that this detail breakdown should be included within the MPAS Validation Rules Document. The Proposer highlighted that since the MIF was raised the number of rejections they had been receiving had reduced significantly and asked the group if they would like to continue the post implementation review. IREG agreed that there was still an issue with how the rejections of both sets of Data Flows and how they are corrected. IREG noted further that data and an understanding of the types of problems occurring would aide them in coming to a solution.

IREG considered gathering further data from Electralink on the volumes of D0304 and D0312 Data Flows sent across the Data Transfer Network, the amount of these Data Flows which had been accepted and the volumes which had been rejected. IREG noted that this request may potentially require the request from MRASCo Executive Committee. The group discussed other potential routes to gather further information would be to issue a Request for Information (RFI) to Suppliers and Meter Operators (MOps). This information would help to identify issues that the MOp community are having with the process and Suppliers in order work out a solution to fix the problems or understand what other data may be required to supplement the analysis of the issue from Electralink. IREG agreed that a RFI would be drafted and the questions to be asked and for it to be issued to industry with a deadline to allow for discussion at the December 2019 IREG meeting.

MIF303 – Amendments to the MAP 28 as a result of the Smart Export Guarantee

The Proposer highlighted that MAP 28 provides a governed process and an agreed response time for the request, and creation of Export MPANs. The scope of which only includes instillations included in the Feed-In Tariff Scheme, and therefore will not extend to Smart Export Guarantee (SEG) instillations when the scheme goes live on the 1st January 2020. It was advised that whilst reviewing MAP 28 the Proposer had identified erroneous references to incorrect Data Flows, it was suggested that these were fixed alongside the SEG work in the MAP.

The Proposer presented IREG with a strawman MAP 28 incorporating the changes required for the SEG rollout and asked the group for comments on the drafting. IREG advised that MAP 28 and MAP 27 were very similar and suggested discontinuation of MAP 28 with the procedure being incorporated into the current MAP 27. The Proposer agreed to draft a fusion strawman MAP of MAP 27 and MAP 28 and would present this to IREG at the next meeting.

MIF304 – Issue with parties sending D0170 Data Flows

The Proposer advised that their company had received over 6,000 D0170 requests for Domestic Property meter information from a Supplier due to the fact that their Meter Operator (MOA) going into receivership and that there was no advance notice of this bulk request. They advised that this was not the first instance of this nature. IREG were advised that Suppliers using the SoLR process for a change of MOA should in the first instance utilise the processes put in place by the Regulator. The existing Supplier is still required to fulfil their regulated requirements under the various codes to ensure a smooth transfer of the data the to the appointed SoLR. In addition, if the Supplier wishes to obtain information from the Distribution Business then it should enter a bi-lateral agreement re the bulk change of Agent. The Proposer asked IREG for their views on the issue and any possible solutions. The group discussed the MIF and agreed that the governance for this process lies within the BSC Procedures and as such should be discussed in a BSC Forum. The Proposer agreed and advised that a BSC Issue Form would be raised instead. The Proposer agreed to close the MIF.

Safeguarding Customer Working Group

The Safeguarding Customer Working Group representative advised IREG that the SCWG project was still progressing with the water companies to share Priority Service Register (PSR) data via the DTN and D0225 Data Flow. IREG noted that the Joint Programme Board meetings are continuing with the next meeting scheduled for the 10th October 2019 with the main goal being to review the project status, the next steps and set key milestones. It was confirmed that a small number of Water companies had enquired about having their Gateways set up and to be provided with access to the DTN.

CSS Updates to the ECOES URS

IREG were advised that Ofgem’s Faster Switching Programme required changes to central systems within the Industry including ECOES and were provided with an update from the programme’s Design Build Test (DBT) phase. IREG were presented with a version 1.3 and 1.4 of the ECOES Interface Specification which had been updated following the receipt of versions 8.0 and 8.1 of the Central Switching Service (CSS) Physical Interface Design. IREG endorsed the changes to this document. IREG noted that since the September 2019 meeting there had not been any further changes to the previously endorsed ECOES URS and ECOES API Webservice Interface Specification.

Secure Communications

IREG were presented with the Secure Data Exchange Portal (SDEP) Use Cases which had been agreed prior to IREG at a meeting of the SDEP Work Group which had been attended by a number of MRA and SPAA parties as well as the ECOES TSP. IREG were advised that the Technical Specification for the service had been received from the ECOES TSP and was being reviewed and look to be available for IREG to review at the November 2019 meeting. Some concerns were noted by some members of the group but were advised that Work Group had considered those and agreed they were not required. IREG further noted that amendments to naming conventions may be able to be considered at some point if any issues once receive the technical solution. It was highlighted that the legal review by the lawyers had recently been received on the Access Agreement and would require considerations by MRASCo Board first for approval. IREG noted that the MRASCo Board would also look to provide a view on the industry consultation period for the service. IREG were advised that a number of MRA Agreed Procedures (MAPs) would need to be updated to make reference to the SDEP, and that those would be brought to IREG in the coming months.

A BSC Representative provided IREG with a presentation on the activities which have taken place so far since P379 had been raised by the Proposer. It was noted that the activities of the group had been to design a new model for Meter Splitting to allow for a Primary and a Secondary Supplier to a meter for an end consumer be billed along with Settlements and Duos invoicing being correct too. A number of scenarios where presented with different options of how the Data Collection and the Settlement arrangements for the Meter would work. It was advised that a potential Use Cases for this service would be for community energy groups funding a certain percentage of usage. The BSC Representative took IREG through several issues that had been identified such as what would happen if there is Capacity Charging in place on the site or Smart Prepayment metering customers. IREG noted that there would be a need to have some kind of indicator in order to register a customer/Meter in CSS under faster switching. Currently that is done by MPAN, but you may need additional ones for the same site but may not be Related as the Supplier would be different. It was advised that a cost benefit analysis should be undertaken to ensure that the uptake of this service warrants the potential considerable cost although it will need authorisation from Ofgem. The implementation date of this service was predicted to be around 2021.

IREG advised that this could be a difficult time for parties to implement a large change like this with the CSS go live and the roll out of the market wide Half Hourly Settlement happening in 2021-2022 and therefore could be better after the Half Hourly Settlement changes are live.

The next meeting is scheduled for 13th November 2019.

IREG Update September 2019

IREG met on the 11th September 2019 and discussed the following MRA Issue Forms (MIFs) and Electricity Central Online Enquiry Service (ECOES) changes.

MIF219 – Full review of the Working Practice Product Set (WPPS)

IREG received an update of the progress of the review. IREG noted the further analysis carried out on the remaining Working Practices and agreed to continue the review. It noted that there were still Working Practices (WPs) that could be removed from the WPPS due to redundancy. As such it agreed that the drafted Change Proposal (CP) to remove WP76 could be progressed to MDB.

MIF281 – Crossed Meters

The ECOES TSP presented a revised overview of the ECOES element of the Crossed Meter solution process having considered comments made from the previous meeting’s presentation. IREG discussed whether cases should be closed when ECOES has been updated with the meter details or when settlement is corrected. One party questioned the benefit of using another system especially when this may differ to gas, however, IREG noted that Ofgem are keen to see a solution in place as it is currently mandated within the SPAA and therefore a step to delivering what will be required under the REC.IREG felt the concerns from the previous meetings presentation had been addressed by the TSP and the suggested technical amendments had been incorporated into the design. IREG were presented with the draft Crossed Meters MAP which was amended further after a workshop review. IREG walked through the redlined changes and updated the details of the updated version to agree a final draft to be taken forward. IREG agreed that the CP to introduce the new MRA Agreed Procedure for Crossed Meters could now be drafted and submitted into the change process and be presented at September’s MDB (MRA Development Board).

MIF283 – ECOES Upload to Distribution Third Party Systems

IREG were informed that the additional development work for the ECOES enhancement was due to go live in November. IREG agreed for the MIF to be closed.

MIF288 – Industry Contacts Database

IREG was informed that the upgrade to the MRASCo Industry Contacts Database was still in the User Acceptance Testing (UAT) phase. Parties were again encouraged to take part in UAT with one party agreeing to take part. A few issues had been identified which had been raised with the TSP with most issues already rectified. IREG noted that Parties had also been contacted to ensure data for the database was accurate.

MIF294 – Suppliers can require New Connection registrations, without a Meter installed, to be cancelled

The Proposer advised that the draft amendments to the BSCP’s were now with the British Gas SVG representative. The proposer confirmed that this MIF could be parked until November when a status update was next expected.

MIF296 – Review of the Non-Domestic Customer Access to ECOES

IREG noted the papers provided. IREG discussed the fact that there are potentially some issues with the process that needed to be investigated such as what happens, when a customer within the NDC portfolio changes and not part of their portfolio, when a customer within the portfolio sells off some of that portfolio, how are those MPANs within the portfolio taken out. IREG further noted that consideration needs to be assessed regarding the access principles along with whether those companies should be included within the annual audit process. IREG agreed that this was a security issue that should be considered first at the MSC October 2019 meeting.

MIF301 – Post Implementation review of the DTC CP 3554

IREG discussed issues relating to the recently implemented changes to the D0312 Dataflow processing. These included problems validating MAP ID’s and updating historical records. IREG continued to focus on the rules that were in place to correct all D0312 related issues advising that previously these could be manually corrected in ECOES and now actions can only be fixed by issuing new D0312 Data Flows and updating their own systems. IREG discussed the need of having a guidance document to aid parties with issues that arise. IREG noted that the reject codes are set out in the MPRS Validation Rules but do not give enough understanding as to how the validation is and what specifically is being validated as the codes are “short codes”, therefore it would be helpful to try and understanding the detail of those rules for the D0312 and D0304. This would could then either be updated in the MPRS Validation Rules or a separate guidance document could be created.

Parties were encouraged to send issue examples to understand the various scenarios that are occurring so that they can be collated for the next meeting.

MIF302 – Ceasing the Related Meter range of MTCs

The Proposer highlighted that the issue had been raised following the implementation of the new “Related MPAN Indicator (J2245) and changes to MPAS Processing for CSS. The Proposer advised that it was an opportunity to look at the option of removing the related ranges of MTCs from the MDD. The Proposer noted that they felt there were 3 options; 1) Do nothing; 2) Rationalise the range of MTCs or Remove Related MTCs from the MDD. A party noted there was a 4th option removing of the MTC’s as they were not required for billing purposes. Another party confirmed DNO’s require the MTC to map the LLFC to the SSC to ensure the correct tariff is being used and billing of DUOs charges. IREG agreed that plenty of work was required to understand the severity of the issue and whether it was too early to unpick the details at this moment in time. Other opportunities may be better timing to consider the use of MTCs such as when the Radio Tele-switches are removed or revisiting consequentially to the Smart metering roll out and the market wide Half Hourly Settlement as part of targeted review further down the line. IREG agreed the MIF should be closed.

Secure Communications

IREG were presented with an updated draft MAP and were asked for comment on the latest version. The new MAP is setting out the rules of the use of the new service. It was agreed that comments on the MAP and Access Agreement should be sent to the IREG mailbox by 20th September 2019. IREG recommended the Proper to postpone submitting the related MAP CP until the Access Agreement had been legally reviewed in case any consequential changes are needed as a result of that review. One party queried whether the related Use Cases would be incorporated into the MAP. An advisor confirmed the Use Cases will go into the URS and individual MAPS. IREG agreed the updates to the IREG ToR were sufficient and were happy for them to be presented to MDB for final approval.

Safeguarding Customer Working Group

IREG were advised that there was no new progress since there had been no meeting since the last IREG, however everything was still on track as last reported. The only significant update of note was that Utility Weekly Magazine had written a related article but there was no planned date of publication. The Energy and Water companies have requested site of the finished article before it is published. IREG were also informed SPAA voted on the related changes to the PSR codes and this was expected to align with the MRA change due for implementation in February 2020.

CSS Update to ECOES URS

IREG were advised that minor changes had been made to the URS but nothing material was changing. Changes to clause 15.2 are due to be discussed by FSEG so IREG agreed the final version of the change would be brought back to IREG next time. IREG agreed the other two additional minor changes should be approved.